Automated system and method for generating reasons that a court case is cited

ABSTRACT

A computer-automated system and method identify text in a first “citing” court case, near a “citing instance” (in which a second “cited” court case is cited), that indicates the reason(s) for citing (RFC). The automated method of designating text, taken from a set of citing documents, as reasons for citing (RFC) that are associated with respective citing instances of a cited document, has steps including: obtaining contexts of the citing instances in the respective citing documents (each context including text that includes the citing instance and text that is near the citing instance), analyzing the content of the contexts, and selecting (from the citing instances&#39; context) text that constitutes the RFC, based on the analyzed content of the contexts. A related computer-automated system and method selects content words that are highly related to the reasons a particular document is cited, and gives them weights that indicate their relative relevance. Another related computer-automated system and method forms lists of morphological forms of words. Still another related computer-automated system and method scores sentences to show their relevance to the reasons a document is cited. Also, another related computer-automated system and method generates lists of content words. In a preferred embodiment, the systems and methods are applied to legal (especially case law) documents and legal (especially case law) citations.

COPYRIGHT NOTICE. A portion of this disclosure, including Appendices, issubject to copyright protection. Limited permission is granted tofacsimile reproduction of the patent document or patent disclosure as itappears in the U.S. Patent and Trademark Office (PTO) patent file orrecords, but the copyright owner reserves all other copyright rightswhatsoever.

BACKGROUND OF THE INVENTION

1. Field of the Invention

The present invention relates to systems and methods for automated textprocessing, and for automated content and context analysis. Inparticular, the present invention relates to automated systems andmethods of identifying sentences near a document citation (such as acourt case citation) that suggest the reason(s) for citing (RFC).

2. Related Art

In professional writing, people cite other published work to providebackground information, to position the current work in the establishedknowledge web, to introduce methodologies, and to compare results. Forexample, in the area of scientific research, a researcher has to cite todemonstrate his contribution to new knowledge. As another example, inwriting court decisions, a judge has to cite precedent legal doctrine tocomply with the common law tradition of stare decisis. However, theciting in the legal profession is more precise than that in thescientific research community.

Courts deal with legal issues such as points of law or facts in dispute.Issues arise over differences of opinion as to definition,interpretation, applicability of specific facts and acts, priordecisions, legal principles or rules of law. Every court decision orcase involves one or more issues (the reason a law suit was brought). Inaddition, in most cases there are usually several sub-issues that arisefrom the detailed analysis and consideration of the issues. Thus, almostevery case discusses multiple issues.

However, these multiple issues are often not intrinsically related asone might expect in scientific literature. Rather, the issues only occurtogether in a given case because they have a bearing on the specificfactual situation dealt with in that case. Discussion of each issue orsub-issue is usually supported by citing relevant legal authorities,which may not be related to one another.

For example, People v. Surplice, 203 Cal. App.2d 784, is frequentlycited for the general issue of how the court should exercise itsjudicial discretion when the law allows it. But, it is also frequentlycited for the more specific issue that says that it is reversible errorwhen a judge fails to read and consider a probation officer'spre-sentence report.

As a result, when a citing case criticizes a cited case, the citing caseis usually not criticizing the whole case. Most of the time, thecriticism is on a specific legal issue. Similarly, a citing case mayreference a cited case for a specific, supportive point of law.

It is not unusual to read a citing case that both agrees with the citedcase on one issue, and disagrees with it on a different issue.Traditional content analysis techniques that apply statistical models onwhole documents run into difficulty in pinpointing the exact reason acase is cited.

Thus, there is a need in the art to provide a technique that can extractthe reason for citing (RFC) at a local region where the citing instanceoccurs. However, there do not appear to be any conventional systems forperforming the required task of finding text near a citing instance thatindicates the reason a document is cited. It is to fulfil this need,among others, that the present invention is directed. In fulfilling thisneed, the invention provides new applications of techniques that areknown in the art, such as word stemming, informetrics and vector spaceinformation retrieval, which are now briefly discussed.

Porter in [Porter 1980] describes a word stemming algorithm that stripssuffixes from words. This conventional word stemming algorithm handlesmany types of suffixes and is not limited by the length of a word.However, this approach is not computationally very fast and does notperform well on document sets containing many long words, such as courtopinions and medical journal articles. However, Applicants haverecognized that it is desirable to use stemming to find morphologicalvariations of words—that is, words that have different suffixes.Applicants have recognized that, because many input documents(especially court opinions) contain many long words, it is valuable toprovide a stemming method that simply shortens them to their first Nletters (where N is a positive integer such as six). Such an inventivestemming method is described in the Detailed Description.

Informetrics is a term whose definition is somewhat ambiguous in theliterature. It appears to have been first introduced in 1979 as generalterm covering both bibliometrics and scientometrics [Brookes, 1991]. Allthree terms have been used loosely to mean more or less the same thing.Informetrics can be perceived in its broadest sense as “the study of thequantitative aspects of information in any form” [Brookes, 1991, p.1991], or as “the search for regularities in data associated with theproduction and use of recorded information” [Bookstein et al., 1992].

Small [Small 1978], a bibliometrics researcher, found that if oneexamines the text around citing instances of a given scientificdocument, one can determine the ‘particular idea the citing author isassociating with the cited document’. He goes on to say that thecitation of a cited scientific document becomes a symbol for the ideasexpressed in the text of the citing instance. However, court caseopinion citation differs from that of the scientific community in twofundamental ways.

First, in the legal profession, a citing instance is normally for singlepoint-of-law, definition, or fact pattern that is precisely stated nearthe citing instance. In contrast, in the scientific community, a citinginstance is often for very general principles or ideas that are normallynot precisely stated near the citing instance.

Second, in the legal profession, two citing instances of a particularcase are often for differ points of law, definitions, or fact patterns[Morse 1998]. In contrast, in the scientific community two citinginstances are generally for the same principles or ideas that are notclearly stated or imprecisely stated near the citing instance.

Therefore, bibliometrics methods that use just the frequency of citationof documents do not generally work as well when applied to legalcitations as they did when applied to scientific citations. As anexample, take co-citation analysis [Small 1973], which is the analysisof the frequency that two citations appear in the same document. Oneconclusion that co-citation analysis produces is that two documentsciting the same two other documents have a high probability of beingabout closely related topics. But in the legal profession, this is nottrue as often as it is in the scientific community.

For example, if both of two case law documents D1 and D2 cite People v.Surplice, and both documents cite another case for an issue related to“a probation officer's pre-sentence report”, then co-citation analysiswould conclude that these two cases have similar topics. But, if D1cites People v. Surplice for the first very general reason (how thecourt should exercise its judicial discretion), and D2 cites it for the2nd very specific reason (dealing with a probation officer'spre-sentence report), then D1 and D2 could be about very differenttopics.

Accordingly, something more than mere co-citation frequency counts isneeded to determine if two cases are similar in topic. It is to fulfillthis need, among others, that the present invention is directed.

Concerning vector space information retrieval, the “Smart” system[Salton 1989] is an example of an information retrieval system based onthe vector processing model. The goal of the Smart system is to find thedocuments that are similar to a “query” (a list of words). Both queriesand documents are represented as word vectors. In the simple case, eachelement of a word vector is the frequency that a specific word appearsin the document collection.

A simple method of determining the similarity of a document to a queryis to compute the dot product of the document's and query's wordvectors. The dot product is the sum of the products of correspondingelements from the two word vectors, where corresponding elements containthe frequency counts of a given word, either in the document set or thequery. Normally this similarity metric is normalized by taking intoaccount the lengths of the document and query. The present inventionprovides, among other advantages, a new application of the vectorprocessing model and similarity metric like the one described above.

U.S. Pat. No. 5,918,236 (Wical; hereinafter “the '236 patent”) may beconsidered relevant. The '236 patent discloses a system that generatesand displays “point of view gists” and “generic gists” for use in adocument browsing system. Each “point of view gist” provides a synopsisor abstract that reflects the content of a document from a predeterminedpoint of view or slant. A content processing system analyzes documentsto generate a thematic profile for use by the point of view gistprocessing.

The point of view gist processing generates point of view gists based onthe different themes or topics contained in a document. It accomplishesthis task by identifying paragraphs from the document that includecontent relating to a theme for which the point of view gist is based.The '236 patent's Summary of the Invention discloses that the point ofview gist processing generates point of view gists for differentdocument themes by relevance-ranking paragraphs that contain a paragraphtheme corresponding to the document theme that was determined byanalyzing document paragraphs and the whole document.

However, the '236 patent's relevance-ranking does not solve the problemsolved by the present invention—determining which sentences near aciting instance to determine which sentences are the best ones torepresent the reason for citing (RFC). Thus, there is a need in to artto provide a system that relevance-ranks sentences near a citinginstance based on the similarity of each such sentence to typicalcontext of many citing instances for a given document. Furthermore,there is a need to provide a system to determine typical context byanalyzing the context of many citing instances for the same case. It isto fulfill these various needs, among others, that the present inventionis directed.

References:

-   1. Bookstein, A.; O'Neil, E.; Dillion, M.; and Stephens, D., 1992,    “Application of loglinear models to informetrics phenomena”,    Information Processing and Management, 28(1), 75.-   2. Brookes, B., 1991, “Biblio-, sciento-, infometrics??? What are we    talking about?”, Informetrics 89/90, edited by Egghe, L. & Rousseau,    R., Amsterdam, Elsevier, 31-44.-   3. Moor, W. J. 1988, “Citation Context Classification of a citation    classic concerning Citation Context Classification”, Social Studies    of Science, 18, pp.515-521.-   4. Morse, A. L., 1998, “Citation Sources in Michigan Supreme Court    Opinion”, dissertation from University of Michigan, published by UMI    Dissertation Service.-   5. Porter, M., 1980, “An algorithm for suffix stripping, Program”,    Automated Library and Information 14(3), p. 130-137-   6. Salton, G., 1989, Automatic Text Processing: The Transformation,    Analysis, and Retrieval of Information, Addison-Wesley Publishing.-   7. Small, H., 1973, “Co-citation in scientific literature: A new    measure of the relationship between two documents”, JASIS 24(4), p.    265-269.-   8. Small, H., 1978, “Cited Documents as Concept Symbols”, Social    Studies of Science, 8, pp.327-340

SUMMARY OF THE INVENTION

The invention fulfills the various needs described above.

The invention provides a computer-automated system and method foridentifying text, near a citing instance, that indicates the reason(s)for citing (RFC).

The invention further provides a computer-automated system and methodfor selecting content words that are highly related to the reasons aparticular document is cited, and giving them weights that indicatetheir relative relevance.

The invention further provides a computer-automated system and methodfor forming lists of morphological forms of words.

The invention further provides a computer-automated system and methodfor scoring sentences to show their relevance to the reasons a documentis cited.

The invention further provides a computer-automated system and methodfor generating lists of content words.

In a preferred embodiment, the invention is applied to legal (especiallycase law) documents and legal (especially case law) citations.

Other objects, features and advantages of the present invention will beapparent to those skilled in the art upon a reading of thisspecification including the accompanying drawings.

BRIEF DESCRIPTION OF THE DRAWINGS

The invention is better understood by reading the following DetailedDescription of the Preferred Embodiments with reference to theaccompanying drawing figures, in which like reference numerals refer tolike elements throughout, and in which:

FIG. 1 illustrates an exemplary hardware configuration in which theinventive system and method may be implemented.

FIG. 2 is a high-level flow chart of a preferred implementation of theRFC (reason for citing) method according to the present invention.

FIG. 3A is a flow diagram showing a first exemplary embodiment of theFIG. 2 step 203 of generating a content word list.

FIG. 3B is a flow diagram showing a second exemplary embodiment of theFIG. 2 step 203 of generating a content word list. FIG. 3B is like FIG.3A except that it uses the actual text of cited document X, and pairsparagraphs of citing instances of X with paragraphs of X itself.

FIGS. 3A and 3B may be referred to collectively as “FIG. 3.”

FIG. 4 is a flow diagram showing an exemplary embodiment of the FIG. 2step 204 of scoring sentences and selecting those with highest scores asRFCs.

DETAILED DESCRIPTION OF THE PREFERRED EMBODIMENTS

In describing preferred embodiments of the present invention illustratedin the drawings, specific terminology is employed for the sake ofclarity. However, the invention is not intended to be limited to thespecific terminology so selected, and it is to be understood that eachspecific element includes all technical equivalents that operate in asimilar manner to accomplish a similar purpose.

For example, in addition to being applied to legal case law documents(court opinions), the invention may be applied to any other type ofdocument that contains citations. Also, what this specification refersto as a “sentence” may be any text unit that makes up paragraphs.Likewise, what this specification refers to as a “paragraph” can referto any chunk of text that makes up a document and that are made of“sentence” text units.

Definitions of terminology. As used in this specification, the followingterms have the following meanings:

-   -   Citing instance—the citation of a “cited” case X found in        another “citing” case Y. For example, when McDougall v. Palo        Alto School District cites Ziganto v. Taylor, the citation is        referred to as “a citing instance of Ziganto in McDougall.”    -   Content words—words that convey the content of documents.    -   Content word's frequency count—the number of times a content        word is in a paragraph of a citing instance of X.    -   Context of the citing instance—text around a citing instance        of X. For example, the paragraph of a citing instance and the        paragraphs before and after it are one example of a “context” of        the citing instance.    -   Noise words—words that occur in almost all input documents and        therefore do not convey much about the content of any one        document. Noise words are normally removed when analyzing        content. Appendix C has an exemplary list of noise words.    -   Paragraph of a citing instance—the paragraph of some case that        contains a citing instance. For example, the paragraph of        McDougall v. Palo Alto School District that contains a citing        instance of Ziganlto v. Taylor would be called a paragraph of a        citing instance of Ziganto.    -   RFC—the text, such as sentences in the context of a citing        instance of X, that has the largest calculated content score and        that therefore likely indicates the reason a cited document was        cited.

With these definitions established, the structure and operation ofpreferred embodiments of the invention are now described.

Referring to FIG. 1, embodiments of the inventive RFC generation systemmay be implemented as a software system including a series of modules ona conventional computer. An exemplary hardware platform includes acentral processing unit 100. The central processing unit 100 interactswith a human user through a user interface 101. The user interface isused for inputting information into the system and for interactionbetween the system and the human user. The user interface includes, forexample, a video display, keyboard and mouse.

A memory 102 provides storage for data (such as the documents containingthe citing instances, the content word lists, and the noise word list).It also may provide storage for software programs (such as the presentRFC generation process) that are executed by the central processingunit. An auxiliary memory 103, such as a hard disk drive or a tapedrive, provides additional storage capacity and a means for retrievinglarge batches of information.

All components shown in FIG. 1 may be of a type well known in the art.For example, the system may include a SUN workstation including theexecution platform SPARCsystem 10 and SUN OS Version 5.5.1, availablefrom SUN MICROSYSTEMS of Sunnyvale, Calif. The software may be writtenin such programming languages as C, C++ or Perl. Of course, the systemof the present invention may be implemented on any number of computersystems using any of a variety of programming languages.

Exemplary embodiments of the inventive methods provided by the inventionare now described.

Briefly, in a particular preferred embodiment of the invention, the textof documents that cite a particular document X is input. Then, thesystem extracts from each of these documents, text around each citinginstance of X (that is, the “context” of a citing instance of X). Thesystem then uses paragraphs containing the citing instances of X, foundin the contexts, to generate a list of content words. It then uses thelist of content words to calculate a content score for each sentence ineach context of each citing instance of X, and selects the sentenceswith the highest score as the RFC for that citing instance of X.

Embodiments of the inventive method are now described in greater detail.

Referring to FIG. 2, a high-level flow chart of the RFC generationmethod is shown. Block 200 represents input of the text of documents(such as court opinions) that cite a document X, which is by pertinentexample a court opinion.

Block 201 is the step of dividing the documents into “paragraphs” (orother suitable entity), and dividing each “paragraph” into “sentences”(or other suitable sub-entity). One way to divide a case into paragraphsis to assume that blank lines separate paragraphs. To divide paragraphsinto sentences, it may be assumed that sentences always end with atleast four lower case letters that are immediately followed by a period.These two assumptions do not divide cases perfectly into paragraphs, nordo they divide paragraphs perfectly into sentences, but it is anadvantage of the inventive RFC determination method that it does notrequire perfect divisions.

Table 1 illustrates an exemplary way that the text of court opinions canbe input to this invention. Table 1 shows that each sentence of a casethat cites X is assigned

-   -   a) an index for the paragraph it is in, and    -   b) a sentence index.

In the illustrated example, sentences are entered in the order theyappear in the case. In addition, the sentence containing a citation of Xis marked and the citation in the sentence is marked. For example, inTable 1, sentence 5 contains the citation of interest, Ziganto v.Taylor, 198 Cal. App. 603, and is marked with an asterisk in theparagraph number column. Also, the citation of that sentence is enclosedwith sgml tags:

<citation> . . . </citation>. TABLE 1 The “Context” of a citing instanceof Ziganto, from McDougall plus paragraph and sentence indexing Para-Sen- graph tence Num- Num- ber ber Sentence Text 1 1 We have not beenreferred to, nor have we found, any case upholding the plea of resjudicata in the precise instant situation. 1 2 For the reasons we havegiven above, we are persuaded that such plea cannot be availed of“offensively” in the case before us and that the effect of the originalgrant should be determined anew and independently of the earlier action.2 3 We therefore turn to the original deed of William Paul. 2 4 Since noextrinsic evidence was introduced in the court below, the constructionof the deed presents a question of law.  2* 5 We are not bound by thetrial court's interpretation of it, and we therefore proceed, as it isour duty, to determine the effect of its foregoing provisions accordingto applicable legal principles. <citation>(Estate of Platt (1942) 21Cal. 2d 343, 352 (131 P. 2d 825); Jarrett v. Allstate Ins. Co. (1962)209 Cal. App. 2d 804, 809-810 (26 Cal. Rptr. 231); Ziganto v. Taylor(1961) 198 Cal. App. 2d 603, 606 (18 Cal. Rptr. 229), Moffatt v. Tight(1941) 44 Cal. App. 2d 643, 648 (112 P. 2d 910).)</citation> 3 6Appellants contend that the deed in question created a fee simpledeterminable in the school district with a possibility of reverter inthe original grantor, his heirs and assigns. 3 7 We have concluded thatsuch contention has merit.*(the asterisk) marks the paragraph and sentence that contains thecitation of interest, namely, the citation to Ziganto.

Referring again to FIG. 2, in block 202 the system determines a“context“(surrounding text) for all citing instances of X. The contextof all citing instances of X is used in steps 203 and 204, discussedbelow.

Block 203 represents the step of generating a content word list. Twoexemplary implementations of this step are described below, withreference to FIGS. 3A and 3B.

Block 204 represents the step of scoring sentences, and selecting thosesentences with the highest score (or other enhanced selection technique)as being the desired RFCs. This step is described in greater detail withreference to FIG.4.

Finally, block 205 represents the output of the FIG. 2 process, namely,RFCs for each citing instance of X.

Next, the process' steps and alternate embodiments thereof are describedin detail, with reference to a particular example.

After the text of the legal cases citing X is input (step 200) andparsed into paragraphs and sentences (step 201), the “context” for allciting instances of X is obtained as follows. Table 1 shows the text ofa case that cites X divided into paragraphs and sentences. Step 202 usesthe X citation marker (which accompanies the citing sentence in Table 1)to locate the paragraph containing a citation to X. For each citinginstance of X, an exemplary implementation of step 202 extracts:

-   -   the paragraph containing the citation to X (paragraph 2 in Table        1);    -   the paragraph before the paragraph containing the citation to X        (paragraph 1 in Table 1); and    -   the paragraph after the paragraph containing the citation to X        (paragraph 3 in Table 1).    -   In this embodiment, these three paragraphs are considered the        “context of the citing instance of X.”

Of course, variations on this choice of context lie within the scope ofthe invention. In any implementation, an important consideration is tohave enough context so that sentences that are in fact relevant to why acase is cited is included in the context. Also, it is important thatthere be at least a few sentences in the context, so that scoring andselecting step 204 has more than one sentence to score and choose from.Further, it is important for the context determination step to accountfor short paragraphs, and paragraphs of citing instances at thebeginning or end of a document. These are conditions that mightotherwise cause the context to be too small (contain too few sentences).

Alternative examples of methods of determining the context are:

-   -   selecting only the paragraph containing the citing instance; or    -   selecting M sentences before the citing instance and N sentences        after the citing instance, where M and N are different may be        variable.

However the context is determined, the context of each citing instanceof X is used by steps 203 and 204.

Block 203 represents the step of generating content word list. Contentword list generation step 203 (detailed in flow diagram in FIGS. 3A and3B) inputs the context for each citing instance of X from step 202. Step203 also uses a previously-generated “Noise word” list, exemplified inAppendix C.

The steps in first and second exemplary embodiments of step 203 aredescribed with reference to FIGS. 3A and 3B, respectively.

Referring first to FIG. 3A, in step 300A paragraphs of citing instancesfrom the contexts of the instances of X are paired (associated with eachother). Each paragraph of a given citing instance of X is paired withevery other paragraph of a citing instance of X that is not in the samecase as the given citing instance.

As an example, consider a hypothetical situation in which there are fourciting instances of case X—one citing instance in case A, two citinginstances in case B, and one citing instance in case C. The citinginstances may be denoted as:

-   -   1A, 2B, 3B, 4C        where the letter in the denotation indicates the citing case. If        this denotation is used to label the four paragraphs containing        these four citing instances, then the pairs created by step 300A        would be:    -   1A—2B    -   1A—3B    -   1A—4C    -   2B—4C    -   3B—4C

Paragraphs 2B and 3B are not paired because they are in the same case.

The following is an example of one pair of paragraphs for citinginstances of Ziganto v. Taylor. The citing cases are McDougall v. PaloAlto School District, 212 Cal. App. 3d 422, and Jarrett v. AllstateIris. Co., 209 Cal. App. 2d 804.

Ziganto in McDougall: We therefore turn to the original deed of WilliamPaul. Since no extrinsic evidence was introduced in the court below, theconstruction of the deed presents a question of law. We are not bound bythe trial court's interpretation of it, and we therefore proceed, as itis our duty, to determine the effect of its foregoing provisionsaccording to applicable legal principles. (Estate of Platt (1942) 21Cal.2d 343, 352 (131 P.2d 825); Jarrett v. Allstate Ins. Co. (1962) 209Cal.App.2d 804, 809-810 (26 Cal. Rptr. 231); Ziganto v. Taylor (1961)198 Cal.App.2d 603, 606 (18 Cal. Rptr. 229); Moffatt v. Tight (1941) 44Cal.App.2d 643, 648 (112 P.2d 910).)

Ziganto in Jarrett: The construction of the instant contract is one oflaw because it is based upon the terms of the insurance contract withoutthe aid of extrinsic evidence. Accordingly, we are not bound by thetrial court's interpretation of it, but it is our duty to make the finaldetermination in accordance with the applicable principles of law.(Estate of Platt, 21 Cal.2d 343, 352 (131 P.2d 825); Ziganto v. Taylor,198 Cal.App.2d 603, 606 (18 Cal. Rptr. 229).) Our interpretation does,however, coincide with that made by the trial court.

Step 301 is the step of removing anything that is not a word, from bothparagraphs of a pair. In this example, step 301 results in the followingtwo lists of words:

Ziganto in McDougall: We therefore turn to the original deed of WilliamPaul Since no extrinsic evidence was introduced in the court below theconstruction of the deed presents a question of law We are not bound bythe trial court interpretation of it and we therefore proceed as it isour duty to determine the effect of its foregoing provisions accordingto applicable legal principles

Ziganto in Jarrett: The construction of the instant contract is one oflaw because it is based upon the terms of the insurance contract withoutthe aid of extrinsic evidence Accordingly we are not bound by the trialcourt interpretation of it but it is our duty to make the finaldetermination in accordance with the applicable principles of Ourinterpretation does however coincide with that made by the trial court

Step 302 is the step of inputting (or referring to previously-input)noise words from a noise word list. Appendix C illustrates a noise wordlist that may be used in this embodiment.

Step 303 is the step of removing noise words from both paragraphs. Forthis example, step 303 results in the following two lists of non-noisewords:

Ziganto in McDougall: turn original deed William Paul Since extrinsicintroduced below construction deed presents bound interpretation proceedduty determine effect foregoing provisions according applicable legalprinciples

Ziganto in Jarrett: construction instant contract based terms insurancecontract aid extrinsic bound interpretation duty make finaldetermination accordance applicable principles interpretation howevercoincide made

Step 304 is the step of stemming the remaining non-noise words of bothparagraphs by shortening them to their first N letters (N is a positiveinteger) when any has more than N letters to begin with. (The choice ofexactly six letters is somewhat arbitrary, and the exact number ofletters may of course be varied while still remaining within the scopeof the present invention.) Then, the resulting stemmed words arealphabetized. For this example, stemming step 304 results in thefollowing two lists of stemmed non-noise words:

Ziganto in McDougall: accord applic below bound constr deed deed determduty effect extrin forego interp introd legal origin Paul presen principrocee provis Since turn Willia

Ziganto in Jarrett: accord aid applic based bound coinci constr contracontra determ duty extrin final howeve instan insura interp interp mademake princi terms

Step 305 is the step of determining the “common” stemmed, non-noisewords—those stemmed, non-noise words that are in both paragraphs of apair. In this example, step 305 results in the following list of stemmednon-noise words that are common to the two paragraphs:

accord applic bound constr determ duty extrin interp princi

Step 306 is the step of tallying each common, stemmed, non-noise word'sfrequency count by adding one to its frequency count for each paragraphin the pair that has not been processed by this process. Because theparagraphs in the example are the first two paragraphs processed by thisstep, each of the above stems has a frequency count of exactly 2 becauseeach is in both paragraphs in the pair. However, as paragraphs after thefirst two paragraphs are processed, the numbers of some of the stemsgrow to higher than 2 as the stems are again encountered.

Step 307 is the step of designating as content words, the non-noisewords whose stems are the common stemmed non-noise words. In thisexample, these words are:

accordance according, applicable, bound, construction, determinationdetermine, duty, extrinsic, interpretation, principles

In the above list of words, different morphological forms of the sameword (“accordance” and “according”) are separated by a space and not bya comma. These forms are associated because they have the same first sixletters.

This completes discussion of this one application of FIG. 3A to a singlepair of paragraphs. Appendix A shows a complete list of content wordsand associated tallied frequency counts generated by the FIG. 3Aembodiment when applied to all paragraphs of citing instances.

The invention provides that the content word list may be supplementedand/or restricted by additional techniques. Such supplementation and/orrestriction of the content word list constitute optional steps shownschematically as optional step 308.

For example, the content word list may be supplemented with specificwords and phrases that often indicate legally significant text. Forexample, words that might specifically indicate concise expression ofrules of law, or words indicating how the citing case is treating thecited case, are meaningful and may thus be included in content wordlists. Such words include, for example, “following,” “overruling,”“questioning,” and so forth.

Conversely, the content word list can be restricted by other techniques.For example, it is possible to require a non-noise word to be in morethan a given number M paragraphs of citing instances (M>2, for example).Words in the content word list that do not meet this criteria areremoved from the list.

Further, it is possible to remove from the content word list, non-noisewords to be in at least M paragraphs of citing instances (M≧2, forexample), along with W other non-noise words. For example, if M=2 andW=3, then the non-noise word “injury” would be a content word because itis in two paragraphs of citing instances with the other three non-noisewords “insured”, “vehicle”, and “coverage”.) Words in the content wordlist that do not meet this criteria are removed from the list.

Variations of the content word generation method lie within thecontemplation of the invention, based on at least the followingobservations.

The FIG. 3A method of generating a list of content words (which includescomparing the text of each paragraph of a citing instance of X to thetext of other paragraphs of citing instances of X), results in the samelist of content words as taking all the non-noise words that haveoccurred in at least two paragraphs of citing instances of X. However,by viewing the process as taking words in common that result from acomparison of two sets of paragraphs, the resulting content words couldbe very different if the two sets of paragraphs are very different.

Also, referring now to FIG. 3B, a second embodiment of the method ofgenerating content words compares paragraphs of citing instances of X toparagraphs in the Majority Opinion of X itself. One situation in whichit is advisable to use the second embodiment to generate content wordsis when case X has not been cited often. In this situation, there willbe few paragraphs of citing instances to compare.

Still another alternative embodiment involves combining paragraphs ofciting instances with paragraphs from the Majority Opinion of X, andcomparing each paragraph of a citing instance with both.

The second embodiment of FIG. 2 step 203 is now described with referenceto its decomposed flow diagram in FIG. 3B. Input used by thisalternative embodiment is different from that used by FIG. 3A, andincludes the context for each citing instance of X and the text of thelegal case X itself. As in FIG. 3A, the final output of method of FIG.3B is a list of content words.

Briefly, the second embodiment of the method of generating a list ofcontent words includes comparing the text of each paragraph of a citinginstance of X to the text of each paragraph in the Majority Opinion ofX. Like the first embodiment, each time two paragraphs are compared, theresult is a list of words they have in common, and these common wordsare the words that become the content words.

Comparing two paragraphs in the FIG. 3B embodiment may be chosen to begenerally the same as the comparing process in the FIG. 3A embodiment.For the FIG. 3B method, each paragraph of X itself is paired with eachparagraph of a citing instance of x, as shown in step 300B which is theonly step different from its corresponding step in FIG. 3A. As anexample, consider the hypothetical situation in which there are:

-   -   three citing instances of case X; and    -   four paragraphs in the Majority Opinion of X.

In this situation, each of the three paragraphs of the three citinginstances are paired with each of the four paragraphs of the MajorityOpinion of X, yielding 3×4=12 pairs of paragraphs.

The description of the second embodiment is abbreviated, it beingunderstood that the foregoing discussion of FIG. 3A applies tocorresponding steps in FIG. 3B.

Applying this technique to the concrete example includes pairing theciting paragraph in McDougall to the second paragraph of the MajorityOpinion of Ziganto:

McDougall: We therefore turn to the original deed of William Paul. Sinceno extrinsic evidence was introduced in the court below, theconstruction of the deed presents a question of law. We are not bound bythe trial court's interpretation of it, and we therefore proceed, as itis our duty, to determine the effect of its foregoing provisionsaccording to applicable legal principles. (Estate of Platt (1942) 21Cal.2d 343, 352 (131 P.2d 825); Jarrett v. Allstate Ins. Co. (1962) 209Cal.App.2d 804, 809-810 (26 Cal. Rptr. 231); Ziganto v. Taylor (1961)198 Cal.App.2d 603, 606 (18 Cal. Rptr. 229); Moffatt v. Tight (1941) 44Cal.App.2d 643, 648 (112 P.2d 910).)

Ziganto 2^(nd) paragraph: Appellant is the owner of a lot in Palo Altoupon which he arranged for the construction of an apartment house by ageneral contractor. During the course of construction respondent, asubcontractor and material man, at the request of the contractorfurnished certain cabinets and other materials of a claimed value of $5,075.21 which were used in the building. On Jan. 26, 1959, respondentfiled for record his claim of lien in the above amount.

After removing everything not a word, removing noise words, andshortening to their first N=6 letters those words having more than sixletters, the potential content words in McDougall and Ziganto are:

McDougall: accord applic below bound constr deed deed determ duty effectextrin forego interp introd legal origin Paul presen princi proceeprovis Since turn Willia

Ziganto 2^(nd) paragraph: above Alto amount apartm arrang buildi cabinecertai claim claime constr constr contra contra course During furnishouse Januar lien lot materi materi owner Palo record reques responrespon subcon used value

The following is the “list” of words in common (in this case, a list ofone word) that therefore becomes the sole contribution of this pair ofparagraphs to the content word list:

Construction

A complete list of content words generated for this example by allparagraphs processed by the FIG. 3B embodiment is provided in AppendixB.

Of course, it is envisioned that still further methods, and variationsof methods, may be used to generate lists of content words, in additionto those shown in FIGS. 3A and 3B.

Referring again to FIG. 2, step 204 represents the step of scoring text(such as sentences) and selecting those with the highest score(s) as theRFC. An RFC may be one or more sentences. Step 204's decomposed flowdiagram is shown in FIG. 4.

The following describes calculation of a content score using, as anexample, the first sentence in the context of the citing instance ofZiganto in McDougall. The first sentence in this context (the first rowin the body of Table 2) is the focus of discussion of individual stepsin FIG. 4. Table 2 shows the sentences of this example's context, alongwith the values calculated by the steps in FIG. 4.

In Table 2, there are seven sentences, one in each row. There are sevencolumns in Table 2:

-   -   1) The column labeled “Sentence . . . ”, contains:        -   a) the text of sentences in the context,        -   b) each content word found in the sentences, and        -   c) each content word's respective frequency count,            determined from the content word list such as one or more of            those shown in Appendix A or Appendix B.    -   2) The column labeled W shows the number of words in the        sentence.    -   3) The column labeled ICS shows the sentence's initial content        score.    -   4) The column labeled NICS shows the normalized initial content        score.    -   5) The column labeled D shows the sentence's distance, in number        of sentences, from the citing instance of Ziganto, which in this        case is the fifth sentence.    -   6) The column labeled MAD shows the modified absolute value of        distance D after it has been modified by steps 403 and 404 (FIG.        4).

7) The column labeled CS shows each sentence's calculated content score.TABLE 2 Sentence, content words in sentence, and each content word'sfrequency count W ICS NICS D MAD CS We have not been referred to, norhave we found, 23 3 0.02 −4 6 0.01 any case upholding the plea of resjudicata in the precise instant situation. (instant(3)) For the reasonswe have given above, we are 41 8 0.02 −3 5 0.01 persuaded that such pleacannot be availed of “offensively” in the case before us and that theeffect of the original grant should be determined anew and independentlyof the earlier action. (determined(8)) We therefore turn to the originaldeed of William 10 0 0.00 −2 2 0.00 Paul. Since no extrinsic evidencewas introduced in the 20 21 0.13 −1 1 0.13 court below, the constructionof the deed presents a question of law. (extrinsic(7) below(3)construction(6) presents(5)) We are not bound by the trial court'sinterpretation 33 52 0.19 0 0 0.19 of it, and we therefore proceed, asit is our duty, to determine the effect of its foregoing provisionsaccording to applicable legal principles. (Estate of Platt (1942) 21Cal. 2d 343, 352 (131 P. 2d 825); Jarrett v. Allstate Ins. Co. (1962)209 Cal. App. 2d 804, 809-810 (26 Cal. Rptr. 231); Ziganto v. Taylor(1961) 198 Cal. App. 2d 603, 606 (18 Cal. Rptr. 229); Moffatt v. Tight(1941) 44 Cal. App. 2d 643, 648 (112 P. 2d 910).) (bound(7)interpretation(8) duty(6) determine(8) provisions(4) according(6)applicable(7) principles(6)) Appellants contend that the deed inquestion created 29 8 0.04 1 5 0.02 a fee simple determinable in theschool district with a possibility of reverter in the original grantor,his heirs and assigns. (determinable(8)) We have concluded that suchcontention has merit. 8 5 0.08 2 6 0.03 (concluded(5))

Referring to FIG. 4, step 400 is the step of calculating an initialcontent score (ICS) for the sentence as the sum of the frequency countsof all content words in the sentence. In the example in Table 2, theonly content word in the first sentence is ‘instant’, whose frequencycount (from Appendix A) is 3. Therefore, the initial content score (ICS)for the first sentence is 3, which is entered in the ICS column of thefirst row of Table 2. As another example, the fourth sentence has fourcontent words whose frequency counts total 7+3+6+5=21, so that 21 islisted in the ICS column of row 4.

The ICS may be normalized to provide a fairer and more meaningfulcontribution to the final content score CS that is ultimatelycalculated.

Block 401 is the optional step of normalizing the initial content scores(ICSs) to arrive at normalized initial content scores (NICSs). In apreferred embodiment, normalization is accomplished by dividing the ICSby the product of the number of words in the sentence (W) and by thelargest frequency count of any content word in the content word list(Appendix A). In the first row of Table 2, the number of words in thesentence is 23 and the largest frequency count in the list of contentwords of Appendix A is 8. Therefore, the NICS (rounded to 2 decimalplaces) is 3/(8*23) or 0.02, which is entered in the first row of theNICS column in Table 2.

Block 402 is the step of determining the number of sentences between thepresent sentence and the closest citing instance of X. This number ofsentences is the distance D for the present sentence. Sentences beforethe closest citing instance are assigned negative numbers, and sentencesafter the citing instance are assigned positive numbers. In the exampleof Table 2, the distance D of the first sentence is −4, which is enteredin the first row of column D of Table 2.

The distance D may be modified according to strategic criteria toprovide a more meaningful contribution to the final content score CSthat is ultimately calculated.

Sentences that are a greater distance D from the citing instance areinitially assumed to be less relevant as reasons for citing. To enhancethe meaning of the distance measurement, the invention envisionsoptional steps that take the absolute value of the distance, and enhancethe absolute distance based on one or more strategic criteria. Thecriteria relate to predetermined statistical observations of theimplications of placement of a sentence in the citing document relativeto the citing instance. The modification of the raw distance measurementD to arrive at a Modified Absolute Distance (MAD) figure is describedwith reference to steps 403 and 404.

Block 403 is the step of adding some penalty number, such as 2, to theabsolute value of the distance D—if the sentence is not in the paragraphcontaining the citing instance of X. In the example of Table 2, thefirst sentence is not in the paragraph containing the citing instance ofZigato, but is in the paragraph before the paragraph of the citinginstance. Therefore, MAD, the modified absolute value of its distance D,becomes 6 after step 403 is executed.

Block 404 is the further step of adding another penalty, such as 2, tothe MAD—if the sentence is after the citing instance of X. In theexample of Table 2, the absolute value of the distance does not changefor the first sentence because it is before, not after, the citinginstance of Ziganto. Thus, in Table 2, MAD remains 6 after step 404.

The invention encompasses means of modifying the distance D to arrive ata modified absolute distance MAD, based on criteria other than theforegoing criteria (whether the sentence of interest is in a differentparagraph as the citing instance, or is recited after the citingsentence). Also, the size of the “penalty” may be a value other than 2.Moreover, a number may be subtracted from the absolute distance so as tofunction, not as a penalty, but as a bonus. Thus, steps 403 and 404 arenot only optional, but are exemplary and non-limiting.

Block 405 is the step of calculating the content score CS of thesentences. This calculation may be accomplished in a variety of ways.However, the following way incorporates a balancing of the value of thecontent word scores (reflected in the value of NICS) and the sentence'sdistance from the citing instance (reflected in the value of MAD). Inthis exemplary method of calculating CS:

-   -   if MAD>2, CS is calculated by dividing NICS by MAD^(0.5).    -   if MAD≦2, CS is simply chosen as NICS.

In the first sentence of Table 2, the absolute value of the distance is6, which is greater than 2. Therefore, its content score CS (rounded to2 decimal places) is 0.02/6^(0.5) or 0.01, which is entered into the CScolumn in the first row of Table 2.

Block 406 represents the RFC selecting'step, in which the one or moresentence(s) with the largest content score(s) are determined to be theRFC. In the example of Table 2, the fifth sentence has the highestcontent score (0.19). Therefore, if only one sentence is selected, thefifth sentence would be the RFC.

In an alternative embodiment in which more than one sentence is selectedas the RFC, the one or more sentences with the next-higher contentscores would be selected as the RFC (for example, starting with thefourth sentence of Table 2, which has a CS of 0.13). As a still furtheralternative, specific sentences may always be included as part of an RFC(for example, the sentence containing the citing instance and/or thesentence immediately before the citing instance's sentence.) Of course,strategies may be combined to form new strategies for selecting the RFC.Thus, the scope of the invention should not be limited to the particularselection criteria described above.

The invention envisions enhancements, improvements, and alternateembodiments of the scoring and selection process in FIG. 4. For example,when the normalized initial content score NICS of every sentence of acontext is small, or when the sentence with the highest scoring sentenceis far from the citing instance, RFC sentence selection may be improvedby one or more of the following techniques.

For example, the invention provides for using a different content wordlist, or using two or more content word lists generated by differentmethods (such as the respective methods shown in FIGS. 3A and 3B). Whenthe normalized initial content scores of all sentences are small whenusing a only one list of content words, the scores may not all be smallwhen using another content word list or when using more than one contentword list.

Alternatively, if the sentence with the highest CS is too far from theciting instance, a closer sentence whose score is not as high, but stillacceptable, is selected.

The inventive methods having been described above, the invention alsoencompasses apparatus (especially programmable computers) for carryingout the methods. Further, the invention encompasses articles ofmanufacture, specifically, computer-readable memory on whichcomputer-readable code embodying the methods may be stored, so that,when the code is used in conjunction with a computer, the computer cancarry out the methods.

A non-limiting, illustrative example of an apparatus that the inventionenvisions is described above and illustrated in FIG. 1. The apparatusmay constitute a computer or other programmable apparatus whose actionsare directed by a computer program or other software.

Non-limiting, illustrative articles of manufacture (storage media withexecutable code) may include the disk memory 103 (FIG. 1), othermagnetic disks, optical disks, “flash” memories, conventional 3.5-inch,1.44 MB “floppy” diskettes, “ZIP” disks or other magnetic diskettes,magnetic tapes, and the like. Each constitutes a computer readablememory that can be used to direct the computer to function in aparticular manner when used by the computer.

Those skilled in the art, given the preceding description of theinventive methods, are readily capable of using knowledge of hardware,of operating systems and software platforms, of programming languages,and of storage media, to make and use apparatus for carrying out theforegoing methods, as well as computer readable memory articles ofmanufacture that can be used in conjunction with a computer to carry outthe inventive methods. Thus, the invention's scope includes not only themethods themselves, but related apparatus and articles of manufacture.

Appendices

Concerning the content of the following Appendices, see the copyrightnotice at the beginning of the specification.

-   -   Appendix A—List of“Content Words” generated by the method in        FIG. 3A    -   Appendix B—List of“Content Words” generated by the method in        FIG. 3B

Appendix C—List of “Noise Words” APPENDIX A List of “Content Words” andrespective frequency counts generated by the method of FIG. 3A 3 absence5 accept 5 accepted 6 accordance 6 accorded 6 according 2 added 2administrative 2 administratively 2 adopted 2 adoption 2 agency 2agreement 4 aid 7 applicability 7 applicable 7 application 2 april 2august 3 based 2 basis 2 begun 3 below 7 bound 2 calculating 2 child 2civil 4 commenced 4 commencement 4 commences 4 commencing 7 computation7 computed 7 computing 5 conclude 5 concluded 5 conclusion 5 conclusions2 conflict 2 conflicting 2 conflicts 2 consent 4 consider 4consideration 4 considered 2 constitute 2 constituted 6 construction 6constructions 3 contract 2 count 6 date 8 day 8 determination 8determine 8 determining 2 drawn 2 during 6 duty 3 erroneous 2 establish2 established 2 establishes 4 event 7 exclude 7 excluded 7 excludes 7excluding 2 expiration 7 extrinsic 4 february 4 final 2 findings 4 first2 fn 4 followed 4 following 3 footnotes 3 generally 2 given 2 haley 2hand 2 holiday 3 identical 2 inferences 2 inquiry 3 instant 2 instrument8 interpretation 8 interpretations 8 interpreted 2 introduced 3 issue 2italics 2 language 2 legal 2 likewise 4 made 5 make 3 making 3 meaning 3month 2 months 2 omitted 2 order 7 period 2 plain 5 present 5 presented5 presents 6 principles 2 procedure 5 provide 5 provided 5 provides 4provision 4 provisions 2 refused 2 release 2 released 2 resort 2resorted 2 respect 2 respectively 2 respondents 3 six 2 stated 2 support2 supported 6 terms 2 then 2 therefrom 2 thus 7 time 2 unless 2 urges 3written

APPENDIX B List of “Content Words” and respective frequency countsgenerated by the method of FIG. 3B 2 above 6 accordance 6 accorded 6according 2 added 3 agreement 2 allegation 2 allegations 3 april 2argument 3 august 2 between 2 certain 3 civil 2 claim 2 claimed 4commenced 4 commencement 4 commences 2 complained 2 complaint 2computation 2 computed 6 conclude 6 concluded 6 conclusion 6 conclusions5 construction 5 constructions 2 contained 2 contains 2 continued 2continuously 3 contract 3 contractor 7 date 9 day 2 days 2 decision 2decisions 4 determination 4 determine 4 determined 4 determining 2entered 5 event 2 excluded 2 excludes 2 excluding 2 executed 2 execution3 expiration 3 first 5 followed 5 following 3 given 2 include 2instrument 2 issues 3 language 2 mentioned 2 necessarily 2 necessary 2new 2 order 2 parties 8 period 3 present 3 presented 3 procedure 2properly 2 property 6 provide 6 provided 6 provides 6 providing 3provision 3 provisions 2 reasonable 2 request 2 requested 3 respondent 3respondents 2 same 2 stipulated 2 stipulation 3 terms 3 then 2 thereof 8time 3 unless 2 used 3 written 2 ziganto

APPENDIX C List of “Noise Words” a about accordingly act acts afteragain against ago all already also although am among an and another anyapp appeal appellant appellants appellate appellee appellees appropriateappropriately are argue argued as at away be became because been beforeboth but by cal can cannot case cases cf ch chicago citation citationscite cited civ co code could court courts defendant defendants diddistrict do doc does done down each end enough erred error even everevidence existing fact facts few fewer filed footnote footnotes for fromgeneral good had has have he held her here him his how I if ill inincluding into is it its itself judge judgment just last later law lawsless like many may me mere merely might more moreover most much must mynear nevertheless no not now nv of on once one only or other othersotherwise our ours out over own par penal per petition petitionedpetitioner petitioners plaintiff plaintiffs pp probably proceedingproper pursuant question questioned rely rev right rights rule rulesruling said say says section see set shall she should so some stat statestatute still subdivision subsection such supra th than that the theirtheirs them there therefore these they this those though to told tootoward towards trial under up upon us use very was way we well were whatwhen where whether which while who wholly whom whose will with withinwithout would yet you your

Modifications and variations of the above-described embodiments of thepresent invention are possible, as appreciated by those skilled in theart in light of the above teachings. For example, the particularprogramming language used, the hardware platform on which the inventionsare executed, the medium on which the executable code is recorded, theparticular method of generating a word list, the particular method ofscoring sentences, the particular method of selecting the reasons forciting based on scores, the particular method of calculating orenhancing any of the various scores used in the methods, the particularvalues of parameters and criteria used during execution of the methods,and the like, may be varied by those skilled in the art while stillremaining within the scope of the invention. It is therefore to beunderstood that, within the scope of the appended claims and theirequivalents, the invention may be practiced otherwise than asspecifically described.

1-4. (canceled)
 5. An automated method for selecting content words from documents, and for determining content scores for respective content words that indicate the content words' degree of relevance, the method comprising: associating paragraphs from the documents; processing text in the associated paragraphs to eliminate text that conveys little about the content of the paragraphs; determining common words that are not eliminated by the processing step and that are found in plural paragraphs, while tallying content scores that indicate respective numbers of paragraphs in which the respective common words are encountered; and forming the content word list as including the common words linked to respective content scores.
 6. The method of claim 5, wherein the paragraph associating step includes: pairing paragraphs from among documents that cite a cited document.
 7. The method of claim 5, wherein the paragraph associating step includes: pairing paragraphs from a cited document with paragraphs from documents that cite the cited document.
 8. The method of claim 5, wherein the processing step includes: removing from the paired paragraphs, noise words that convey little information about the content of the paragraphs; and stemming the words of the paired paragraphs to a length that preserves their essential character while eliminating characters that convey little information about the word's identity. 9-19. (canceled)
 20. An apparatus for selecting content words from documents, and for determining content scores for respective content words that indicate the content words' degree of relevance, the apparatus comprising: means for associating paragraphs from the documents; means for processing text in the associated paragraphs to eliminate text that conveys little about the content of the paragraphs; means for determining common words that are not eliminated by the processing means and that are found in plural paragraphs, while tallying content scores that indicate respective numbers of paragraphs in which the respective common words are encountered; and means for forming the content word list as including the common words linked to respective content scores.
 21. The apparatus of claim 20, wherein the paragraph associating means includes: means for pairing paragraphs from among documents that cite a cited document.
 22. The apparatus of claim 20, wherein the paragraph associating means includes: means for pairing paragraphs from a cited document with paragraphs from documents that cite the cited document.
 23. The apparatus of claim 20, wherein the processing means includes: means for removing from the paired paragraphs, noise words that convey little information about the content of the paragraphs; and means for stemming the words of the paired paragraphs to a length that preserves their essential character while eliminating characters that convey little information about the word's identity. 24-34. (canceled)
 35. A computer-readable memory that, when used in conjunction with a computer, can carry out an automated method for selecting content words from documents, and for determining content scores for respective content words that indicate the content words' degree of relevance, the computer-readable memory comprising: computer-readable code for associating paragraphs from the documents; computer-readable code for processing text in the associated paragraphs to eliminate text that conveys little about the content of the paragraphs; computer-readable code for determining common words that are not eliminated by the processing computer-readable code and that are found in plural paragraphs, while tallying content scores that indicate respective numbers of paragraphs in which the respective common words are encountered, and computer-readable code for forming the content word list as including the common words linked to respective content scores.
 36. The computer-readable memory of claim 35, wherein the paragraph associating computer-readable code includes: computer-readable code for pairing paragraphs from among documents that cite a cited document.
 37. The computer-readable memory of claim 35, wherein the paragraph associating computer-readable code includes: computer-readable code for pairing paragraphs from a cited document with paragraphs from documents that cite the cited document.
 38. The computer-readable memory of claim 35, wherein the processing computer-readable code includes: computer-readable code for removing from the paired paragraphs, noise words that convey little information about the content of the paragraphs; and computer-readable code for stemming the words of the paired paragraphs to a length that preserves their essential character while eliminating characters that convey little information about the word's identity. 39-45. (canceled) 